PRIVACY NOTICE
Privacy Notice for the Processing of Personal Data
of Vip Lounge Customers
In compliance with the Organic Law on Personal Data Protection (LOPDP), the Galápagos Ecological Airport informs its current and future VIP Lounge customers about the use and protection of their personal data, in accordance with the following provisions:
1. Who is responsible for my data?
The Galápagos Ecological Airport is the entity responsible for managing your personal data. We do so in accordance with the Organic Law on Personal Data Protection (LOPDP) and its Regulation.
Address: Baltra Island, Galápagos, Ecuador
Phone: (05) 2534004
Contact email / DPO: dpo@ecogal.aero
The Data Protection Officer (DPO) oversees compliance with the regulations and handles inquiries or requests from data subjects.
2.How do we obtain your data?
- We may receive your data in the following ways:
- Directly from you: when you provide it through any means.
- From the company you represent: if you act as its proxy, partner, shareholder, or representative.
- During the commercial relationship: data generated as part of our interactions.
- Public sources: official records or publicly accessible databases.
- Companies we work with: if there is a legal basis for doing so. In such cases, we will inform you.
If you provide data belonging to third parties, you guarantee that you have obtained their consent and have informed them about this Privacy Notice.
3. What data do we process?
- We only process the information necessary to fulfill the purposes described:
- Identification data: first name, last name, ID card or passport number, job position, company.
- Contact data: phone number, email address, physical address.
Contractual data: billing information, reservations, memberships, or contracted services.
4. What do we use your data for?
Your personal data is used for the following legitimate and specific purposes:
Client and operations management (collections):
Activities to follow up on client accounts, including pending invoices, payment reminders, and coordination of collections.
Internal analysis, statistics, and client communication:
Use of data to generate reports, evaluate service performance, identify trends, and maintain communication with clients.
Issuing invoices and receipts:
Generation of tax and accounting documents that support transactions made with clients.
Preparing contracts and forms:
Drafting and managing documents that formalize commercial relationships, agreements, and service requests.
Reservation processing:
To provide VIP Lounge services.
Membership management:
To validate access to VIP Lounges.
Passenger control management and statistical reporting.
Your data will never be used for purposes other than those stated, without your prior and explicit consent.
5.Legal basis for processing
- We process your data because:
- You provided your consent when you shared your information with us.
- It is necessary to comply with a contract.
- There is a legitimate interest on the part of the Galápagos Ecological Airport, such as ensuring the proper functioning of the commercial relationship, airport security, access controls, among others.
- We must comply with legal obligations.
6. Who do we share your data with?
- ECOGAL may share your data only when:
- It is necessary to execute the contract or comply with legal obligations.
- You provide your consent.
- There is a request from a competent authority.
The possible recipients are:
- Internal ECOGAL departments (operations, billing, customer service).
- Public entities and regulatory authorities.
- Service providers such as technology services, messaging, security, payment processors, legal or tax advisors.
If any international data transfer is carried out, ECOGAL will ensure compliance with the conditions established in Chapter IX of the LOPDP and that the recipient country offers adequate levels of protection or valid contractual clauses.
7. Your rights as a data subject
- You may exercise the rights recognized by the LOPDP:
- Access to your personal data.
- Rectification or updating.
- Deletion or anonymization, when applicable.
- Objection or suspension of processing.
- Portability of your data to another provider.
- Withdrawal of consent.
- Not to be subject to automated decisions without your involvement.
To exercise these rights, you may use the following channels:
- Email: dpo@ecogal.aero
- Physical form: available at ECOGAL offices or for download at www.ecogal.aero
Requirements:
- Copy of the data subject’s identification (ID card or passport).
- Clear description of the right you wish to exercise.
- If represented by someone else, documentation proving legal authorization.
Response time: 15 business days from the receipt of a complete request, in accordance with Chapter III of the LOPDP.
You may also file a complaint with the Superintendence for Personal Data Protection (SPDP) at www.spdp.gob.ec
8. How do we protect your data?
- ECOGAL applies technical, organizational, and legal measures to protect the confidentiality, integrity, and availability of your personal data, such as:
- Access control and limited permissions.
- Encryption and secure storage.
- Internal audits and access logs.
- Confidentiality agreements with staff and service providers.
- Retention and secure deletion policies.
In the event of a security breach that may affect your rights, ECOGAL will notify the data subject and the SPDP within the timeframes established by law.
Although we work to ensure security, no system is 100% infallible
9. Retention period
Your data will be retained for the duration of the commercial relationship and for a maximum period of 7 years thereafter, in accordance with legal and tax obligations.
After this period, the data will be securely deleted or anonymized.
10. Updates to the Privacy Notice
ECOGAL may update this notice when there are changes in the purposes of processing, applicable regulations, or protection measures.
The current version will always be available at www.ecogal.aero and at the company’s facilities.
11. Contact
For inquiries, requests, or complaints regarding this notice or the processing of your personal data, you may contact the Data Protection Officer (DPO):
Email: dpo@ecogal.aero
Phone: (04) 216 9444
Address: Av. De las Américas, Corporate Building, 1st Floor, Guayaquil – Ecuador